Testing of pesticides takes place mostly on active ingredients not final product formulations

Pesticide products may be much more toxic than the active ingredients alone

Adverse reactions of pets to pesticide products may not be on the label

Professional pesticide applications to turf linked to canine malignant lymphoma in dogs

Possible medical impacts of pesticide exposures by Dr. Mark Winston

Pesticides are legally classed as “economic poisons” in most state and federal laws, …” (Ware G., Complete Guide to Pest Control, 2nd edition)

“Federal law specifically prohibits manufacturers of pesticides from labeling their products as `safe, non-poisonous, non-injurious, harmless or non-toxic,’ even when accompanied by a qualifying phrase such as `when used as directed.’”(40CFR:162.10(a)(5)(ix)) These specific prohibitions reflect the process of balancing risks and benefits through which pesticides undergo registration with the USEPA and enter the market for public use. (Letter from Peter Lehner, August 23, 2000)

In December 2003, a case brought by New York State’s Attorney General, Elliot Spitzer against Dow Chemical for promoting the company’s EPA registered insecticide, chlorpyrifos as “safe” was settled for $2 million.The Dow Company’s fine was for “misleading consumers…[in ads] that may have endangered human health and the environment by encouraging people to use the product without proper care.” (The Daily Gazette, Dec. 16, 2003)

ADHD has been associated with organophosphate pesticides at exposure levels common among US children (Bouchard, M.F., Attention-Deficit/Hyperactivity Disorder and Urinary Metabolites of Organophosphate Pesticides,” Pediatrics, V125, #6, June 2010, pp 1270-1277)

Groups considered more sensitive to pesticides: Unborn children are considered by toxicologists to be the population most vulnerable to adverse effects of chemicals including pesticides. Physicians have advised pregnant women to avoid or minimize exposure to pesticides (Peters, P., et al, ed., Section 2.23.6 in Drugs During Pregnancy and Lactation, Treatment Options and Risk Assessment, Shaefer, Cristof, et al, 2nd edition, 2007, 576-581.) Other sensitive groups are the very young, and the elderly (National Pesticide Information Center, NPIC)

In humans accidental exposure to 2,4-D has been linked to a “slow developing, persistent nerve problem…severe muscle pains, inability to walk because of muscle weakness, sensory deficit to pain, touch and heat in both hands and feet…with slow improvement over a 12 month period.” (p. 357, Ecobichon & Joy, Pesticides and Neurological Disease, 2nd ed 1994)

In humans risk of Parkinson’s Disease/parkinsonism has been associated with use of 2,4-D. (Tanner, CM et al, “Occupation and Risk of Parkinsonism,” Arch Neurol, v 66, #9, Sept 2009)

Unless wildlife are listed under the Endangered Species Act (ESA) – which most are not – they are not well protected from landscape pesticides.According to Dr. Chuck Benbrook, “In the real world of pesticide regulation birds, fish and bees are expendable.” (Benbrook, C., “Prevention, not profit should drive pest management,” Pesticides News, 82, Dec. 2008, 12-17). Neonicotinic-type insecticides have been linked to the decline in bee populations according to Dr. vanEnglesdorp. (Schlossberg, T., & J. Schwartz, “A Bumblebee Gets New Protection on Obama’s Way Out,” The New York Times, 1-11-17)

For dogs, the widely-used herbicide, 2,4-D is more hazardous than for laboratory rodents (the usual surrogate for humans in toxicity testing) In the canine body, 2,4-D remains unchanged for a period up to 40 times longer than in the rodent body. In the researcher’s words: “The results show that a body burden of 2,4-D in the dogs is significantly higher than in the rat…which is consistent with the increased sensitivity of the dog to 2,4-D toxicity.” (van Ravenswaay, et al, “Comparative metabolism of 2-4-dichlorphenoxyacetic acid (2,4-D) in rat and dog,” Xenobiotica, V33, no 8, Aug. 2003, 805-821). Landscape pesticide product labels (for USEPA-registered products) may advise a specific time – 6 hours- during which to avoid contact between dogs and grass after a chemical herbicide treatment. A comparable time recommended by veterinary toxicologists for dogs to not contact pesticide-treated turf is 24- 48 hours after treatment (P. 505, Osweiler, et al Small Animal Toxicology, 2011)

After contact with 2,4-D and similar phenoxy herbicides dogs have shown: loss of appetite, diarrhea, vomiting, , excessive salivation, eye or skin irritation, loss of balance, tremors as well as muscle weakness and hind limb stiffness, mild seizures and kidney function may be mildly adversely affected (Osweiler, et al Small Animal Toxicology, 2011)

A young healthy dog developed life-threatening kidney failure due to phenoxy herbicides. It happened as a result of exposure to a lawn, soon after the herbicide spraying had occurred. The product used, contained three active ingredients that still may be used together on lawns by professional landscapers. (Missanelli, M.G., “Death of a pet and chemicals used on lawns,” The Philadelphia Inquirer, Oct. 6, 1986)

Dogs exposed to the broad-spectrum herbicide, glyphosate have been reported to show: salivation, vomiting, diarrhea and other signs of illness. (Campbell and Chapman, Handbook of Poisoning in Dogs and Cats)

Under the present laws governing pesticide registration the sponsors (manufacturers) don’t have to prove their products cause no harm. If citizens petition to have a pesticide product cancelled the petitioners have to prove it is sufficiently toxic for the EPA to ban it.

The USEPA reviews test data supplied by the manufacturer on chemical pesticide active ingredients but does not test most of the pesticide active ingredients or the pesticide products that contain them. Most of the required tests are limited to pesticide active ingredients alone, not the actual pesticide products that are marketed. Marketed pesticide products include active ingredients and other ingredients.

A 2014 scientific study found that compared to active ingredients alone, pesticide products could be up to 1000 more toxic to human cells (Mesnage, R., et al, “Major Pesticides are More Toxic to Human Cells Than Their Declared Active Principles,” BioMed Research International, V.2014, Article ID 179691, 8 pages)

Adverse reactions of pets to chemical pesticides used on landscapes are not required to appear on the label of pesticide products and even when received by the EPA are not necessarily reviewed by EPA employees.

A 2012 report from veterinary and medical institutions found that dogs had a significantly higher risk (70%) of developing Canine Malignant Lymphoma when exposed to pesticides applied by professionals to residential lawns. (Takashima-Uebelhoer, et al, “Household chemical exposures and the risk of canine malignant lymphoma, a model for human non-Hodgkin’s lymphoma,” Environmental Research, 112(2012) 171-176) CML is one of the most common cancers in dogs. Researchers have found that Scottish terriers can develop bladder cancer when exposed to chemical pesticides used on landscapes. (Glickman, L.T., et al, “Herbicide exposure and the risk of transitional cell carcinoma in the urinary tract of Scottish terriers,” JAVMA, 224(8), April 15, 2004)

“Pesticides have medical impacts as potent as pharmaceuticals do, yet we know virtually nothing about their [multiple exposure] synergistic impacts on our health or their interplay with human diseases.” (Dr. Mark Winston, in “Our Bees Ourselves,” The New York Times, 7-13-14)